S. 92C : Transfer Pricing-Arm’s length price-Sale of power by eligible unit claiming deduction u/s 80-IA to non-eligible units-Market for electricity regulated-CUP Method-Rates charged by SEB constitute appropriate external CUP. [S. 80-IA(8), 92BA, 260A]

S. 64 : Clubbing of income-Minor child-Income includes loss-Loss of minor can be clubbed in mother’s hands and not necessarily only in father’s hands-Order of Tribunal set aside. [S.64(IA), 260A]

S. 56 : Income from other sources-Capital gains-Agricultural land-Interest on enhanced compensation for acquisition of land-Interest on delayed payment under the Land Acquisition Act partakes the character of compensation-Eligible for exemption u/s 10(37) where land is agricultural-Not “interest” u/s 2(28A), hence S. 56 not attracted. [S. 2(28A), 10(37), 45, 56(2)(viii), 145, Land Acquisition Act,1894, S. 28, 34, Art. 300A]

S. 50C : Capital gains-Full value of consideration-Stamp valuation-Transfer of leasehold rights-Provision is applicable in respect of transfer of leasehold rights in the lands which were transferred by the MIDC in favour of the assessee. [S. 2(14)(a), 50C, 260A]

S. 43B : Deductions on actual payment-Provision towards approved gratuity fund-Payment made to LIC gratuity fund approved by the CIT-Deduction allowable-S. 40A(7)(b) being specific provision overrides S. 43B. [S. 40A(7)(b)]

S. 40(ba) : Amounts not deductible-Association of persons-Private specific trust-Interest paid to beneficiaries-Order of Tribunal disallowing the interest is affirmed. [S. 260A]

S. 32 : Depreciation-Written-down value-Block of assets-Amalgamation-Approval of Central Government under S. 72A not required where assessee is not claiming carry forward of unabsorbed depreciation but only adopting correct WDV of amalgamating company’s assets. [S. 2(11), 32(2), 43(6), 72A]

S. 12AA : Procedure for registration –Trust or institution-Cancellation of registration-Principal CIT need not await a decision of the assessing authority concerned before passing an order cancelling the registration-Order of the Tribunal is set aside and appeals are remanded back to the Tribunal for a fresh consideration. [S 12A, 254(1)]

S. 11 : Property held for charitable purposes-Cricket association-Applicability of proviso to S. 2(15)-Matter is remitted to the authority concerned to decide the same afresh in view of the ratio decided by the apex Court in Asstt. CIT (E) v. Ahmedabad Urban Development Authority (2022) 329 CTR 297 (SC). [S. 2(15), 260A]

Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015

S. 10(1) : Undisclosed Foreign Assets – Assets acquired prior to commencement of the Act – Settlement Commission – Proceedings cannot continue once dispute is settled under Chapter XIX-A of the Act . [ Income -tax Act 1961 , S. 148 , 245C, Art. 226 ]